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90837 Denials Explained: Duration, Documentation & Payer Rules You Must Follow

CPT 90837 — the 60-minute psychotherapy code — is the highest-paying routine therapy code.
And because it pays well, insurers audit it aggressively.

If your documentation, timing, or coding doesn’t match payer expectations, the claim is immediately denied or flagged for audit.

This guide breaks down exactly why 90837 gets denied, the rules you must follow, and the documentation that will protect your clinic from payer pushback.

1. Why 90837 Gets Denied So Often

Insurance companies treat 90837 as a “high-utilization, high-risk” code.

The most common denial reasons:

✔ Session does not meet required duration

✔ Missing or incorrect time documentation

✔ Insufficient clinical complexity

✔ Therapist uses 90837 too frequently

✔ Incorrect place of service (telehealth rules vary)

✔ Poor or non-skilled documentation

✔ Payer requires prior auth (many do)

✔ Provider not credentialed for 90837 with that payer

✔ Patient plan excludes 90837

Even a small documentation gap can trigger an audit.

2. Exact Duration Rules for 90837 (Very Important)

90837 is not governed by the 8-minute rule.
It has a strict psychotherapy time range.

Required time: 53–60 minutes face-to-face psychotherapy

If your clinical time is:

52 minutes or less → Payer expects 90834 (45-min session)
53 minutes or more → You may bill 90837

If your documentation does not include time in/time out → automatic denial.

3. What Must Be Documented for 90837

To avoid denials or payer audits, documentation must include:

✔ Time in and time out

Example:
Time in: 2:00 PM
Time out: 3:02 PM
Total time: 62 minutes

✔ Modality used (CBT, DBT, insight-oriented therapy, etc.)

✔ Clinical necessity

Explain why the longer session was required.

✔ Patient progress or lack of progress

Quantitative and specific.

✔ Therapists’ interventions

Not generic wording — must be skilled.

✔ Symptoms, risks, or complexity justifying the 60-minute session

✔ Mental status observations

Mood, affect, insight, judgment, behavior.

Payers deny 90837 when the note looks identical to a 90834 note.

4. Payer Policies That Providers Forget

Different insurers have strict internal 90837 rules:

Aetna

Flags high 90837 frequency
Reviews clinical necessity strictly

UnitedHealthcare

Often requires authorization
Heavily audits pre/post COVID telehealth use

BCBS

Some plans cap the number of 90837 sessions
Documentation must show complexity

Cigna

Wants evidence of medical necessity for extended therapy
Progress must be clear and measurable

If you don’t know each payer’s policy → you will get denials.

5. Top Mistakes That Trigger 90837 Denials

1. Documentation does not reflect a 60-minute session

Only “45–50 minutes” documented → denial.

2. Time in/time out missing

Payers treat missing time as non-billable.

3. Therapist bills 90837 for every visit

High-frequency billing = audit flag.

4. Low-complexity cases billed as 90837

Example:
Routine adjustment disorder → payer flags.

5. Providing “supportive therapy” only

Supportive therapy without skilled intervention = denial.

6. Billing 90837 via telehealth incorrectly

Some plans don’t allow 90837 via telehealth or require modifiers.

6. How to Avoid 90837 Denials Completely

Here is the clean workflow top behavioral health clinics use:

✔ Always document time in + time out

Absolute non-negotiable.

✔ Show clear clinical necessity

Why 60 minutes was needed — not “patient talked about stress.”

✔ Use evidence-based modalities

CBT, DBT, EMDR, ACT, trauma-focused therapy — not general talk therapy.

✔ Track frequency of use per patient

Don’t bill 90837 for every session unless medically justified.

✔ Follow payer-specific telehealth rules

Correct POS code, modifier, and UHC rules.

✔ Keep notes detailed

Vague notes = denial.

7. When Should You NOT Bill 90837?

Do not bill 90837 when:

Session lasted less than 53 minutes
Therapy was mostly supportive
No clinical complexity requiring 60 minutes
Group or family therapy occurred
Documentation is weak
Provider spent time on admin tasks
Patient is stable and does not need extended session

Bill 90834 instead.

Final Takeaway

CPT 90837 pays well, but it’s the most audited psychotherapy code in behavioral health.
Clinics that don’t follow duration rules or strong documentation standards lose thousands in denied claims and post-payment recoupments.

By following the correct:

Time thresholds
Documentation structure
Payer rules
Clinical justification requirements

…you will minimize denials and protect your revenue.